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if the specified amount and payment amount were the same amount, it would result in situations where the payment amount at section 1833(a)(1)(EE) was a negative number

5 The Federal Trade Commission Smokeless Tobacco Report for 2015 reported that moist snuff sales have risen every year since 1987 and now surpass the combined sales of all other forms of smokeless tobacco

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However, the phase-in of payment reductions set forth in PAMA for years 4 through 6 after PAMA implementation, whereby payment cannot exceed 15 percent per year as compared to the amount established the prior year, has not yet occurred

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